From: "jeffrey E." <[email protected]>

From: "jeffrey E." <[email protected]> To: Richard Joslin < Subject: Re: Questions on BRH Date: Wed, 04 Nov 2015 14:28:03 +0000 simple i want to see the tax calculation if he sells 1million shares at 20. tra tufts. basis .? has it changed if he were to sell it last year.? On Wed, Nov 4, 2015 at 9:11 AM, Richard Joslin > wrote: The table at the bottom is the tax basis adjustments on a year by year basis (summarized from BRH K-1's). Bottom right indicates net positive taxable income in excess of distributions. Note that $99mm was distributed in Feb 2015 that is attributable to 2014 taxable income. From: Katie Gregory Newman [mailto: Sent: Friday, October 30, 2015 5:49 PM To: Richard Joslin Subject: Questions on BRH Rich, Thanks for your email — sorry our schedules didn't fit today. On Monday I will be in Luxembourg — it might be easiest for us to connect late my time, so do you have any availability in the late afternoon EST? I understand from a few conversations with John Suydam and others that your and Jeffrey's focus is on ensuring that Leon's "negative basis" is limited to his deferred Tufts gain from the 2007 leveraged distribution which is a known amount. Jeffrey indicated that there was some concern that this amount could have increased as a result of cash distributions in excess of tax allocations (accompanied by additional allocations of AMH liabilities). I asked our tax compliance group to compile the cash and tax data over the past 5 years and received the following. You will see that the fact that cash was greater than taxable income in 2013 and 2014 was largely due to the unwinding of the "Harvest" transaction which occurred in 2012. To the extent that taxable income continues to match cash in the aggregate over the years, I believe we can affirm that Leon's "negative basis" is limited to his deferred Tufts gain from the 2007 leverage distribution. Does this make sense to you? Happy to discuss more next week at your convenience. EFTA00841534 EFTA00841535 EFTA00841536